AML Policies, Procedures for an MSB

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Question:

I work for a convience store which is registered as a MSB. Our banker told us we would need to write a policies and procedures. Could you help with a sample or example. Or would you know where I might find one? We currently cash checks and sell money orders.

Answer:

The first thing you should do is visit www.msb.gov to learn all the BSA (Bank Secrecy Act) requirements for your business. Registering is just the first step, now you must make sure you have all the proper policies and procedures in place to ensure compliance. Your bank is responsible for monitoring your BSA program and will need to make sure they are comfortable with it in order to keep you as a customer. Your BSA program will be very similar to a banks BSA program, which is responsible for appointing a compliance officer, annual training, independent audits, properly identifying your customers, reporting certain transactions, record retention, and identifying suspicious activity.

Click here to see an example of a bank policy www.bankersonline.com/tools/amlsamplepolicy.pdf First published on BankersOnline.com 12/6/04